Most efforts in designing vehicle seats for maximum occupant protection have mainly been directed toward protecting the vehicle occupant in frontal crash situations since the vehicle operator is more likely to be involved in a frontal crash situation in an accident. However, lately more attention has been directed in the designing of seats in situations where the occupant's vehicle is struck from the rear. Protection of the vehicle occupant when struck from the rear becomes more challenging when utilizing a recliner seat rather than the typically stiffer, non-recliner seat which was popular in the past. A simple solution to providing more protection to the seat occupant is to increase the thickness and strength of the materials utilized. However, a simple strengthening of the seat is typically unacceptable due to the fact that increased weight diminishes the environmental efficiency of the vehicle.